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25 September 2013 Internal T.I. 2013-0476311I7 F - 93(2), 93(2.01) - Share substituted -- summary under Subsection 248(5)

The second part of paragraph 248(5)(a) expands the scope of this concept in envisaging an indeterminate number of substitutions, establishing a link between the initial property under consideration and the property acquired in the final substitution. ...

17 April 2013 External T.I. 2013-0475301E5 F - Résidence principale - changement d'usage partiel -- summary under Paragraph 45(1)(c)

The elections in subsections 45(2) and 45(3) cannot be made in the situation under consideration. ...

6 July 2012 Internal T.I. 2012-0440741I7 - stock option benefit derived by US resident -- summary under Subparagraph 115(1)(a)(i)

On January 1, 2009, the US employee was granted stock options by Canco in consideration for his duties of employment performed for USCo and, when the options were exercised, USCo paid Canco a sum equal to the in-the-money value of the options at the time of such exercise. ...

2012 Ruling 2011-0410181R3 - Variation of trust indenture -- summary under Paragraph 108(2)(b)

Accordingly, AB Trust will transfer the AB Property (utilizing the s. 97(2) rollover) to an LP (AB LP) formed by it (as general partner) and the Trust (as limited partner), in consideration for the issuance of GP units and the assumption of the AB Trust Notes, which then will be repaid by AB LP by way of set-off against the subscription price by the Trust for LP units. ...

2012 Ruling 2011-0410181R3 - Variation of trust indenture -- summary under Disposition

The summary states: No cash consideration or other proceeds of disposition will be received by the unitholders in respect of the diminishment of their rights as a consequence of the amendments. ...

2014 Ruling 2014-0521831R3 - Withholding on interest payments -- summary under Article 11

Proposed transactions US Parent Co will transfer its limited partnership interest in Can LP to US Sub (a wholly-owned LLC that has elected to be a corporation for Code purposes and apparently will not hold significant other assets) for fair market consideration consisting of an interest-bearing Promissory Note and shares of US Sub. ...

12 June 2012 June STEP Roundtable, 2012-0442681C6 - STEP CRA Roundtable June 2012 - Question 2 -- summary under Subsection 160(1)

Subsection 160(1) would not apply to any transfers of property where fair market value consideration is received in return. ...

29 January 2015 Internal T.I. 2014-0544651I7 - Section 85 transfer of Swap Contracts -- summary under Subsection 85(1)

We have also taken into consideration that the… property and values were accurately described. ...

5 July 2012 Internal T.I. 2010-0388551I7 F - Fiducie - retour de sommes -- summary under Subsection 105(1)

However, it should be taken into consideration that she has already been taxed on the income allocated to her by Trust. ...

16 October 2012 External T.I. 2011-0425271E5 F - Small CCPC -- summary under Paragraph 5301(6)(a)

Furthermore, the taxable income and taxable capital employed in Canada of a subsidiary for the taxation year of its winding-up must be taken into consideration for the purposes of paragraphs 157(1.3)(b) and 157(1.4)(b) to determine whether the parent qualifies as a SCCPC [small CCPC] since the parent and the subsidiary are associated in the course of the particular taxation year by virtue of paragraph 256(1)(a). ...

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